performance-based system for post-closure care at msw landfills california integrated waste...

Performance-Based Performance-Based System for Post-Closure System for Post-Closure Care at MSW LandfillsCare at MSW Landfills

California Integrated Waste Management BoardCalifornia Integrated Waste Management Board

Post-Closure Maintenance Period and Financial Post-Closure Maintenance Period and Financial Assurances for Post-Closure Maintenance WorkshopAssurances for Post-Closure Maintenance Workshop

December 6, 2004December 6, 2004

GeoSyntec Consultants


SpeakerSpeaker

Michael Caldwell, PGMichael Caldwell, PG• Sr. Director, WM Environmental Protection, Sr. Director, WM Environmental Protection,

Groundwater ProgramGroundwater Program More than 18 years of RCRA solid and hazardous More than 18 years of RCRA solid and hazardous

waste experiencewaste experience Member of ITRC Alternative Landfill Technologies Member of ITRC Alternative Landfill Technologies

PCC Team PCC Team Representing WM as a member of the EREF PCC Representing WM as a member of the EREF PCC

Technical Advisory PanelTechnical Advisory Panel


CIWMB Regulatory StandardCIWMB Regulatory Standard

27 CCR §21900:27 CCR §21900:• ““The operator of a solid waste landfill The operator of a solid waste landfill

may be released from post-closure after may be released from post-closure after a minimum period of 30 years upon a minimum period of 30 years upon demonstration to and approval by the demonstration to and approval by the CIWMB, the EA, and the RWQCB that the CIWMB, the EA, and the RWQCB that the solid waste landfill no longer poses a solid waste landfill no longer poses a threat to public health and safety and threat to public health and safety and the environment”the environment”


The EREF Performance-Based The EREF Performance-Based Methodology is Designed to:Methodology is Designed to:

Provide the Solid Waste Community with a Provide the Solid Waste Community with a Tool to Make Technically-Defensible Tool to Make Technically-Defensible Decisions Regarding PCC for MSW LandfillsDecisions Regarding PCC for MSW Landfills

To achieve the objectives of 27 CCR To achieve the objectives of 27 CCR §21900 to demonstrate that the landfill §21900 to demonstrate that the landfill does not pose a threat to HH&Edoes not pose a threat to HH&E


USEPA Reference to a Performance-Based USEPA Reference to a Performance-Based Approach to Ending PCCApproach to Ending PCC

“… “… In an approved state, the Director may allow In an approved state, the Director may allow an owner or operator to cease managing leachate an owner or operator to cease managing leachate if the owner or operator can demonstrate that the if the owner or operator can demonstrate that the leachate no longer poses a threat to human leachate no longer poses a threat to human health or the environment.” health or the environment.”

((40 CFR 40 CFR §258.61(a)(2)§258.61(a)(2)

““Concentrations at the points of exposure, rather Concentrations at the points of exposure, rather than concentrations in the collection system, may than concentrations in the collection system, may be used when assessing threats.”be used when assessing threats.”

EPA530-R-93-017, Section 6.6.3EPA530-R-93-017, Section 6.6.3


A Performance-Based System A Performance-Based System for Post-Closure Care at MSW for Post-Closure Care at MSW

Landfills:Landfills:

A Procedure for Providing Long-A Procedure for Providing Long-Term Stewardship under RCRA Term Stewardship under RCRA

Subtitle DSubtitle D


GeoSyntec, MD(Project

Management)

GeoSyntec, MD(Project

Management)

EREFEREF

EPCC Project TeamEPCC Project TeamTech. Advisory Panel• Industry• Regulators• Researchers

Tech. Advisory Panel• Industry• Regulators• Researchers

Industry(Technical Resources and Data)

Industry(Technical Resources and Data)

ProjectTeam

Experts

ProjectTeam

Experts

Other ResourcesITRC

ASTSWMOIndustry LeadersState Regulators

Trade Associations

Other ResourcesITRC

ASTSWMOIndustry LeadersState Regulators

Trade Associations


EREF Project AttributesEREF Project Attributes Scientifically-based method that addresses Scientifically-based method that addresses

PCC on a modular basisPCC on a modular basis New paradigm for data collectionNew paradigm for data collection Conservative assumptions & approachConservative assumptions & approach Rigorous post-decision monitoringRigorous post-decision monitoring

• ConfirmationConfirmation• SurveillanceSurveillance

Will promote proactive landfill practices Will promote proactive landfill practices • e.g., leachate recirculation, liquid e.g., leachate recirculation, liquid

wastes, A-Cap, etc.wastes, A-Cap, etc.


EREF EPCC Project ObjectivesEREF EPCC Project Objectives

Provide a rigorous technical approach to assess Provide a rigorous technical approach to assess and optimize PCC activitiesand optimize PCC activities

Allow More Effective Management of Existing PCC Allow More Effective Management of Existing PCC FundsFunds

Assess conditions early, evaluate landfill status, Assess conditions early, evaluate landfill status, and monitor for the effects of change with two and monitor for the effects of change with two levels of protective monitoringlevels of protective monitoring

Provide Increased Certainty for Operators and Provide Increased Certainty for Operators and Regulators within existing regulationsRegulators within existing regulations

Develop a Develop a Standardized, Performance-Based SystemStandardized, Performance-Based System to Define, Manage, & Ultimately Exit PCC. Intent is to:to Define, Manage, & Ultimately Exit PCC. Intent is to:


Possible Outcome of Implementation of the EREF Possible Outcome of Implementation of the EREF EPPC Methodology (Not >10 Years After Closure)EPPC Methodology (Not >10 Years After Closure)

Continue PCCContinue PCC –– Post-closure care (and Post-closure care (and additional data collection) is still required.additional data collection) is still required.

Optimize PCCOptimize PCC –– Post-closure care must Post-closure care must continue for at least one element but optimization continue for at least one element but optimization of activities does not pose a threat to HH&Eof activities does not pose a threat to HH&E

End of Regulated PCCEnd of Regulated PCC –– The landfill does not The landfill does not pose a threat and de minimus management of pose a threat and de minimus management of end-use obligations are maintained (referred to end-use obligations are maintained (referred to as “custodial care”)as “custodial care”)


Assessment of MSW Landfills in Peer-Assessment of MSW Landfills in Peer-Reviewed Technical LiteratureReviewed Technical Literature

The quality of leachate and LFG in a landfill can The quality of leachate and LFG in a landfill can be correlated to the “phase” of the life of the be correlated to the “phase” of the life of the landfill; landfill;

The factors that affect a landfill as it progresses The factors that affect a landfill as it progresses through each phase of its life are understood and through each phase of its life are understood and can be identified for a particular landfill; andcan be identified for a particular landfill; and

The future trends of leachate and LFG can be The future trends of leachate and LFG can be predicted based on known, current quality and predicted based on known, current quality and knowledge of that phase of its life. knowledge of that phase of its life.

EREF EPCC Report (pending 1Q 2005) EREF EPCC Report (pending 1Q 2005)


MSW Landfill, Up State NYLeachate BOD - East Tank

0

500

1000

1500

2000

2500

3000

3500

4000

4500

Aug-87 May-90 Jan-93 Oct-95 Jul-98 Apr-01 Jan-04

Date

Leach

ate

BO

D c

on

c. (m

g/l)

0.0E+00

5.0E+05

1.0E+06

1.5E+06

2.0E+06

2.5E+06

3.0E+06

3.5E+06

4.0E+06

4.5E+06

Leach

ate

BO

D lo

ad

(g

)

BOD (mg/l)

BOD load (g)

4 per. Mov. Avg. (BOD load (g))


Project StatusProject Status

Final draft of EREF PCC reviewed by Final draft of EREF PCC reviewed by technical team and TAPtechnical team and TAP• Report expected in 1Q 2005Report expected in 1Q 2005

ITRC preparing draft report for team ITRC preparing draft report for team member reviewmember review• Significant input from regulatory Significant input from regulatory

community including CIWMBcommunity including CIWMB• Final report expected to be complete by Final report expected to be complete by

May 2005May 2005


Thank You!Thank You!

Contacts:Contacts:

Mike Houlihan, PE, GeoSyntec ConsultantsMike Houlihan, PE, GeoSyntec Consultants [email protected]@geosyntec.com

Michael Caldwell, PG, WMIMichael Caldwell, PG, WMI [email protected]@wm.com

Ed Repa, PhD, EREFEd Repa, PhD, EREF [email protected]@erefdn.org

mailto:[email protected]


EREF EPCC Technical Advisory PanelEREF EPCC Technical Advisory Panel

Environmental Research and Environmental Research and Education FoundationEducation Foundation

Edward Repa, Ph.D. Edward Repa, Ph.D. Project ManagerProject Manager

Research InstitutionsResearch InstitutionsDebra Reinhart, Ph.D., P.EDebra Reinhart, Ph.D., P.EAssoc. Dean, Civil & Assoc. Dean, Civil &

Environmental EngineeringEnvironmental EngineeringUniversity of Central FloridaUniversity of Central FloridaEREF Board MemberEREF Board Member

Public SectorPublic SectorN.C. Vasuki, P.E., DEEN.C. Vasuki, P.E., DEECEO, Delaware Solid Waste CEO, Delaware Solid Waste

AuthorityAuthoritySWANASWANA

Private SectorPrivate SectorDavid Burt, P.HGDavid Burt, P.HG..Sr. Director, Environmental Sr. Director, Environmental

Protection, Waste Protection, Waste Management, Inc.Management, Inc.

Clarke Lundell, P.E.Clarke Lundell, P.E.Director, Engineering, Republic Director, Engineering, Republic

IndustriesIndustries Regulatory Agency Liaisons Regulatory Agency Liaisons

EPA (OSWER)EPA (OSWER)ASTSWMOASTSWMO (Paul Farrell, (Paul Farrell,

VADEQ)VADEQ)


Project Team ExpertsProject Team Experts

Groundwater Protection• Mr. John Gallinatti, GeoSyntec, CA

Containment Systems• Dr. Rudy Bonaparte, GeoSyntec, GA

Geotechnical Issues• Mr. Mike Houlihan, GeoSyntec, MD

Landfill Gas• Mr. Pat Sullivan, SCS Engineers, CA

Leachate• Dr. Morton Barlaz, NC State Univ.• Dr. Jeremy Morris, GeoSyntec, MD

Data Analysis• Dr. Robert Gibbons, Univ. of

Illinois (Chicago)

Risk Assessment•Toxicology•Public Policy

FIGURE 8MODULE PHILOSOPHY

PERFORMANCE-BASED EPCC PROJECTREVISION 7: 16 JANUARY 2003

DRAFT

Start

Define Approachand PerformEvaluation(s)

Acceptable?

Apply Modification

ConfirmationMonitoring

Completed?

SurveillanceMonitoring

Completed?

Move to NextModule

Yes

No

Yes

HighTriggerFailure

LowTriggerFailure

Yes

LowTriggerFailure

HighTriggerFailure

POST-CLOSURECARE

MAINTENANCEAND/OR

MONITORING

POST-CLOSURECARE

SURVEILLANCEMONITORING

POST-CLOSURECARE WITHIN MODULE

COMPLETED WITH RESPECTTO REGULATORY

FRAMEWORK. OPERATORMUST CONTINUE TO MEET

END-USE OBLIGATIONS.

TAKE NECESSARYACTION

Undo Modification(if Necessary) and

Re-define Approach

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